Listing on HKEX: Main Board Requirements and the IPO Process

Listing on the Stock Exchange of Hong Kong is a demanding process governed by the HKEX Listing Rules and overseen by the Securities and Futures Commission. Most guides describe it in general terms without giving the numbers, which is unhelpful, because the numbers are what determine whether a company is eligible at all.

This guide sets out the actual financial thresholds for a Main Board listing, the public float rules as reformed in 2025 and 2026, the alternative routes for biotech and specialist technology companies, and what the process involves. The figures are those in force as at August 2026.

The three Main Board financial tests

A Main Board applicant must satisfy one of three financial eligibility tests under Rule 8.05.

Profit test

• Profit attributable to shareholders of at least HK$35 million in the most recent financial year; and
• aggregate profit of at least HK$45 million across the two preceding financial years.

There is no separate market capitalisation figure attached to the profit test itself. The general minimum expected market capitalisation of HK$500 million under Rule 8.09(2) applies to every new applicant, and is often mistakenly quoted as a profit-test requirement.

Market capitalisation, revenue and cash flow test

• Expected market capitalisation of at least HK$2 billion at listing;
• revenue of at least HK$500 million in the most recent audited financial year; and
• positive operating cash flow of at least HK$100 million in aggregate across the three preceding financial years.

Market capitalisation and revenue test

• Expected market capitalisation of at least HK$4 billion at listing; and
• revenue of at least HK$500 million in the most recent audited financial year.

Trading record and continuity

All three tests require a trading record of at least three financial years, with management continuity across those three years and continuity of ownership and control for at least the most recent audited financial year.

Under Rule 8.05A, a shorter trading record may be accepted for an applicant using the market capitalisation and revenue test, provided the directors and management have at least three years' experience in the same line of business and management has been continuous for the most recent audited year.

A change of controlling shareholder does not automatically defeat the ownership continuity requirement. HKEX codified its earlier guidance in July 2026: an applicant can still satisfy the test if it demonstrates no material change in influence over management across the relevant period.

Waivers exist for mineral companies under Chapter 18 and for newly formed infrastructure project companies, where the applicant's share of total capital cost is normally at least HK$1 billion and at least fifteen years remain on the concession.

Public float: the rules changed twice

This is the area where older guidance is most likely to mislead. The flat 25% requirement was replaced with a tiered scale on 4 August 2025, and a separate ongoing float regime took effect on 1 January 2026.

Initial public float at listing

Expected market value of the class at listing	Minimum in public hands
HK$6 billion or less	25%
Above HK$6 billion up to HK$30 billion	The higher of the percentage giving HK$1.5 billion in public hands, and 15%
Above HK$30 billion	The higher of the percentage giving HK$4.5 billion in public hands, and 10%

The old discretionary waiver allowing 15% to 25% for applicants above HK$10 billion has been repealed, having been superseded by the tiers.

Initial free float

Rule 8.08A, also effective 4 August 2025, adds a separate requirement. Shares held by the public and not subject to disposal restrictions at listing must either represent at least 10% of the class with an expected market value of at least HK$50 million, or have an expected market value of at least HK$600 million.

Ongoing float

From 1 January 2026, Rules 13.32A to 13.32G replaced the old ongoing float rule. An issuer must maintain either the initial prescribed threshold (25%, or the lower percentage prescribed at listing) or an alternative threshold of a market value of at least HK$1 billion together with at least 10% of the class. Market value is measured on a volume-weighted average price over the 125 trading days before the determination date, and float must now be disclosed in monthly returns and annual reports.

A significant shortfall, meaning float below both 15% (or half the initial prescribed threshold where that was under 25%) and a market value of HK$500 million with at least 5% of the class, now attracts a "-PF" stock marker rather than automatic suspension. Delisting follows if the shortfall is not cured within eighteen months, or twelve months on GEM.

Other Main Board thresholds

• Expected market value of securities held by the public at listing: at least HK$125 million.
• Minimum expected market capitalisation of the applicant: HK$500 million.
• Minimum market value of each class listed: HK$50 million.
• Minimum number of shareholders: 300.
• The three largest public shareholders may not hold more than 50% of the securities in public hands.

Alternative routes

Chapter 18A: biotech

Pre-revenue biotech companies may list under Chapter 18A with an initial market capitalisation of at least HK$1.5 billion, at least two financial years of operation in the current line of business, and working capital covering at least 125% of costs for the following twelve months.

Chapter 18C: specialist technology

The rulebook thresholds are HK$6 billion for a commercial company and HK$10 billion for a pre-commercial company, with commercial revenue of at least HK$250 million. A temporary modification announced jointly by the SFC and HKEX reduces these to HK$4 billion and HK$8 billion respectively for the period from 1 September 2024 to 31 August 2027. Anyone assessing eligibility now should work from the reduced figures and diarise their expiry.

Since July 2026, commercialised biotech and specialist technology companies may also list under Chapters 18A and 18C respectively.

GEM

GEM's cash flow test requires aggregate operating cash flow of at least HK$30 million over two financial years, a two-year trading record, management continuity across two years and ownership continuity for one. A second test, introduced on 1 January 2024, allows a market capitalisation of at least HK$250 million with revenue of at least HK$100 million aggregate over two years showing year-on-year growth, and research and development spend of at least HK$30 million aggregate over two years representing at least 15% of total operating expenditure in each of them.

Minimum total market capitalisation on GEM is HK$150 million, market value in public hands at least HK$45 million, and the minimum number of shareholders is 100.

The streamlined transfer from GEM to the Main Board has been in force since 1 January 2024 as Chapter 9B. An eligible issuer needs three full financial years listed on GEM, a volume-weighted average market capitalisation over a 250-trading-day reference period meeting the relevant Main Board threshold, continuity of ownership and control across those three years, no fundamental change of business, and daily turnover of at least HK$50,000 on at least half the trading days in the reference period. The commercial attraction is what is dispensed with: no sponsor, no listing document or prospectus, no post-hearing information pack, and no initial listing fee.

The process

A listing typically involves a sponsor, which leads the application and conducts due diligence, underwriters, legal advisers to both the issuer and the sponsor, and reporting accountants. The broad stages are:

• appointing advisers and preparatory due diligence;
• corporate restructuring and pre-IPO steps where needed;
• drafting the prospectus and filing the listing application (the A1 filing);
• review and comment by HKEX, and the SFC where relevant, usually over several rounds;
• the listing hearing;
• marketing, the roadshow, pricing and allocation; and
• listing and commencement of trading.

Six to twelve months from formal kick-off to listing is a reasonable planning assumption, though readiness and market conditions move it considerably.

Three procedural developments are worth knowing. Confidential filing was extended to all new applicants in July 2026, having previously been limited. FINI, live since November 2023, compressed IPO settlement from T+5 to T+2. And an accelerated vetting route for eligible A-share issuers, in place since October 2024, commits each regulator to no more than 30 business days after a single comment round, for applicants with an expected market capitalisation of at least HK$10 billion and a clean compliance record over two full financial years. The standard timeframe is 40 business days per regulator after up to two comment rounds.

The Technology Enterprises Channel, launched in May 2025, offers Chapter 18A and 18C applicants confidential filing of the application proof and treats 18A or 18C eligibility as satisfying the innovation test for weighted voting rights.

IPO allocation

The allocation mechanics changed on 4 August 2025. The bookbuilding placing tranche must be at least 40%. Issuers then choose between Mechanism A, with an initial public subscription tranche of at least 5% and clawback triggered at 15, 50 and 100 times subscription, capped at 35%; and Mechanism B, a fixed allocation of at least 10% up to a maximum of 60%, with no clawback.

After listing

A listing brings continuing obligations that are a real management commitment: periodic financial reporting, inside information disclosure, and compliance with the Listing Rules on notifiable and connected transactions. The new ongoing float rules add monthly and annual float disclosure. These obligations should be factored into the decision to list, not treated as an afterthought.

How we can help

Alan Wong LLP advises companies, founders and shareholders on the corporate and commercial work that surrounds a Hong Kong listing: pre-IPO restructuring, shareholder and investor arrangements, the corporate governance changes a listing requires, and continuing obligations once listed. To discuss whether a listing is realistic for your business and what it would involve, please get in touch.

This article is general information current as at August 2026. The Listing Rules are detailed and are amended frequently; the figures above should be confirmed against the current rulebook before you rely on them. It is not legal advice.